Taxation of independent personal services may be taxed in source state if fixed base or prolonged presence triggers source taxation. Income of an individual resident is taxable only in the State of residence, except where the individual has a fixed base in the other Contracting State-then only income attributable to that fixed base may be taxed there-or where the individual's stay in the other State meets a prescribed duration threshold, in which case only income from activities performed in that State may be taxed by that State.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Taxation of independent personal services may be taxed in source state if fixed base or prolonged presence triggers source taxation.
Income of an individual resident is taxable only in the State of residence, except where the individual has a fixed base in the other Contracting State-then only income attributable to that fixed base may be taxed there-or where the individual's stay in the other State meets a prescribed duration threshold, in which case only income from activities performed in that State may be taxed by that State.
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